Updated for April 2023 by Esmeralda Montes, NTL Trust
In my role as a Client Advisor, nearly every day, new prospects seeking a second passport from a Caribbean country reach out to me. More often or not, they start the conversation with one key question. They see the various Caribbean Citizenship by Investment Programmes (CIP) and the types of investments that qualify for CBI and ask: Which Option is Better?
Property investment makes sense to most clients as they mostly already own property in various countries. Initially, therefore, they seem surprised as to why there is a “donation” to a Government program on the table. Although we refer to “Citizenship by Investment”, how can a Donation be deemed an investment?
Often the donation is deemed not an investment by clients as they think they are not getting a return on their investment. Our answer to this, however, is that the new Citizenship is indeed your return on the investment. What better return than increased freedom, security, and business opportunities for you, your children, and your grandchildren?
Investment into real estate, of course, is simpler to understand. Real estate can one day be sold and hopefully at a higher value than the initial purchase price. Even in the worst-case scenario, if you incur some loss on resale, the loss may well still be less than you would have spent on the “Donation” option.
However, which option may be a better decision, depends a lot on your circumstances. The best route for starters is to understand what both options mean in reality.
Which CIPs Offer Both?
The five Caribbean programs include Antigua and Barbuda, Dominica, Grenada, Saint Kitts and Nevis, and Saint Lucia. The programs are quite different in their investment value for both the donation option and real estate. Vanuatu’s program recently made amendments to its Citizenship Act to include investment into real estate as an option.
What are the Investment Criteria?
Single Applicant
There are no government fees associated with the donation amount, as the entire amount goes to the Government. However, there are additional government fees for investment in real estate. Investors need to consider all fees when making a decision on which CIP is best for them.
Investment Options as a Single Applicant
| Investment | Antigua and Barbuda | Saint Kitts and Nevis | Grenada | Saint Lucia | Dominica | Vanuatu |
| Donation | US$ 100,000 | US$ 125,000 LTO until 30, June 2023; US$ 150,000 from 1, July 2023 | US$ 150,000 | US$ 100,000 | US$ 100,000 | US$ 130,000 |
| Real Estate | US$ 400,000 (5yrs holding period) | US$ 200,000 (7yrs holding period); US$ 400,000 (5 yrs holding period) | US$ 350,000 (4yrs holding period) | US$ 200,000 (5yrs holding period) | US$ 200,000 (3yrs holding period) | |
| Split Investment Option | US$ 200,000 (5yrs holding period) | US$ 220,000 (5yrs holding period) | ||||
| Est. Government Fee | US$ 30,000 | US$ 25,000 | US$ 50,000 | US$ 30,000 | US$ 25,000 |
Antigua allows for a split real estate option which reduces the investment amount by US$ 200,000. The Government of Antigua has done this to entice more investors to purchase real estate over the donation route. The doubling of principal applicants enables the Antiguan Government to receive US$ 60,000 in fees (two applicants) instead of one US$ 30,000 government fee for the US$ 400,000 option.
The Vanuatu real estate option (REO) has recently been passed into law. There are four government-approved projects, and the investment amount required is a minimum of US$ 200,000. However, the government fee associated is assumed to be the same for the donation option.
The donation options for Dominica and Saint Lucia are best for single applicants purely based on cost, as their total fees are less than in Antigua.
Family of Four
The family of four options makes for an interesting analysis, and an investor needs to consider how family members might change the initial value considerably. Luckily, Antigua’s program does not change for the donation or real estate investment which might place the program ahead of others. The Antiguan Citizenship by Investment program is arguably the best option for larger families. Especially when it comes to six or more people in an application. The UWI Fund alternative is an ingenious initiative backed by the government to finance the brand new campus of the prestigious University of the West Indies, the foremost institution of higher education in the entire Caribbean area. As part of this scheme, aspirants to the Citizenship by Investment Programme are obliged to invest US$150,000, which covers a family of six or more individuals, with the minimum count of individuals specified as six for each application.
One of the unique advantages of this alternative is that it enables one member of the family to receive a one-year, tuition-only scholarship at the University of the West Indies. This implies that you are not only securing your family’s future through investment but also contributing to the advancement of higher education in the region.
It does seem, purely on a cash flow basis, that Grenada is pricing itself out of the market. However, some of the real estate options in Grenada arguably offer better value-for-money, and guaranteed buy-back options are sometimes available meaning you can resell the investment after the legal holding period.
Investment Options as a Family of Four
| Investment | Antigua and Barbuda | Saint Kitts and Nevis | Grenada | Saint Lucia | Dominica | Vanuatu |
| Donation | US$ 100,000 | US$ 170,000 LTO until 30, June 2023; US$ 195,000 from 1, July 2023 | US$ 200,000 | US$ 150,000 | US$ 175,000 | US$ 180,000 |
| Real Estate | US$ 400,000 (5yrs holding period) | US$ 200,000 (7yrs holding period); US$ 400,000 (5 yrs holding period) | US$ 350,000 (4yrs holding period) | US$ 200,000 (5yrs holding period) | US$ 200,000 (3yrs holding period) | |
| Split Investment Option | US$ 200,000 (5yrs holding period) | US$ 220,000 (5yrs holding period) | ||||
| Est. Government Fee | US$ 30,000 | US$ 60,000 | US$ 50,000 | US$ 55,000 | US$ 35,000 |
The Comparison of Real Estate vs Donation
The decision for an investor primarily comes down to their individual needs and investment appetite. It’s a legitimate concern that inflated property prices might make it difficult for an investor to recoup their initial capital amount. There have been many instances where developments have not gotten off the ground, and the initial investments are sitting idle, not earning any money from rentals or hotel revenue.
Other concerns include the limited range of developments to invest in and the property developments needing to be Government approved. An investor cannot simply pick a property and purchase it to receive citizenship (except in St Kitts and Nevis, with the Approved Private Home Sales option).
These were the initial growing pains of the real estate options for all of the Caribbean programs. Many investors are now opting for real estate investment through improved processes and standards, and Grenada’s program has actually exploded in recent years.
Besides making a return on investment, an investor must of course consider the opportunity cost of time and money. The investment criteria for the programs do not allow an investor to sell before holding for five years (some up to seven years).
Another concern is whether the property will be sold after the holding requirement has lapsed. Property is an illiquid asset and can take several months or even years to sell at times. Access to cash is often king for investment decisions.
Time may also be a crucial decision for an investor to exit their current country of residency. Someone who might have made exceptional wealth from crypto might need to urgently leave their country of residence to avoid significant tax implications.
Successful traders need to consider the opportunity cost of investing an additional couple hundred thousand dollars into a slow-growing property asset versus paying the lower donation amount and having access to trade the money they did not pay across. Opportunity cost is very different for someone who has money sitting in a low-interest Swiss bank account, as opposed to someone who needs working capital in a successful, active business where the annual return might be measured in double or even triple digits.
Is Financing Possible?
Strictly speaking, there is normally no possibility to finance your property purchase to obtain citizenship by investment. There is a requirement to show the source of funds when investing. A second requirement is to show the investor can sustain their lifestyle after investing. i.e. they do not spend their entire net worth on a CIP.
Financing a CIP might, however, be possible in an investor’s offshore country. They would typically borrow against existing assets (for example stock market portfolios), and the total CIP investment sum is paid to the relevant Government from the investor directly. In this case, the financing is done outside the country, and the CBI programs have no problems at all with that.
An access bond is allowed when the existing asset’s value is worth more value than what is required to borrow. More precise information would need to come from individual programs and even the development of choice.
Conclusion
There is no “one size fits all” answer. It is impossible to determine which investment option is best because everybody’s circumstances are different. The decision depends on factors such as the individual investor, their financial circumstance, family situation, and appetite for risk.
The wonderful thing is, however, that there are choices available for different types of investors. More investment options allow for a more significant opportunity to suit more high-net-worth individuals and, essentially, the money flows into the Caribbean.
The only really smart advice is to talk to a professional who knows all six programs and knows both the donation and real estate options back to front. You can save a lot of time and money by talking with a knowledgeable professional. Please reach out to me or one of my colleagues at NTL Trust and use our expert advice to assist you in making a more informed decision on which investment route is best!
